ML20195J743

Responds to NRC Re Violations Noted in Insp Repts 50-413/88-07 & 50-414/88-07.Corrective Action:Resistance Temp Detectors Replaced & Qualified Termination Seal Installed.Fee Paid

ML20195J743
Person / Time
Site:	Catawba
Issue date:	11/23/1988
From:	Tucker H DUKE POWER CO.
To:	NRC OFFICE OF ADMINISTRATION & RESOURCES MANAGEMENT (ARM)
References
NUDOCS 8812050032
Download: ML20195J743 (7)

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(?vt1373 rill DUKE POWER November 23, 1988 Director, Office of Enforcement U. S. Nucicar Regulatory Commission Washington, D.C. 20555 Attention: Document Concrol Desk Subj ect: Catawba Nuclear S'.. Lion. Units 1 and 2 Docket Nos. 50-413 and 50-414 NRC Inspection Report Nos 50-413/88-07 and 50-414/88-07 Reply to Notice of Violation Gentlemen:

Please find attached Duke Power Company's reply to the violations transmitted by M. L. Ernst's letter dated October 24, 1988. Also enclosed is a check for

$50,000 as payment for the violation identified in section I of the letter.

Very truly yours, f

Hal B. Tucker m

PGL/

Attachment xc M. L. Ernst Acting Regional Administrator Region II U. S. Nucicar Regulatory Commission 101 Marietta St., NW, Suite 2900 Atlanta, GA 30323 W. T. Orders NRC Resident Inspector a Catawba Nucicar Station 6 g#

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Catawba Nuclear Station page 1 of 6

. . Duke Power Company Reply to Notice of Violation 413, 414/88-07 10 CFR 50.49(d), (e), (f), (j), and (k), state in part that (1) the licensee shall have a list of electric equipnent important to safety that addresses the environmental conditions, including temperature, pressure, humidity, radiation, chemicals, and submerge,cw; (2) the qualification program must include and be ]

based on submergence if subject to being submerged (3) each item of electric equipment important to safety shall be qualified by testing of. or experience with, identical or similar equipment, and the qualification shall include a supporting analysis to show the equipment to be qualified is acceptables (4) a record of qualification must be maintained in an auditable forms and (5) electrie equipment important to safety which was previously qualifled in accordance with I NUREG-0588 (for comment version), "Interin Stafi Position on Environmental l Qualification of Safety-Related Electrical Equipment," need not be requalified to 10 CFR 50.49.

NUREG-0588, Section 2.2(5) states that "equipment should be located above flood level or protected against submergence by locating the equipment in qualifico

, watertight enclosures...Where equipment could be submerged, it should be

( identified and demonstrated to be qualified by test for the duration required."

1) Contrary to the above, from the initial operation of Unit i under the full power license issued on January 17, 1985 until January 1988, the Reactor Coolant System (RCS) hot and cold leg wl.le range resistance temperature l ictectors (RTD), Model RdF, vero not qualified in that the junction boxes acre the RTD pigtail wires were terminated could become submerged and were not qualified for submergence the RTD wires were not qualified for submergence in the installed configuration, that is, the hydrostatic hose assembly that was to encapsulate the wires to prevent moisture intrusion had been removed during installation; and the qualification file did not address the installed configuration as being different from .no tested configuration i due to submergence. '

2) Contrary to the above, from the initial operation of Unit 2 under the full power license issued on May 15, 1986, until January 1988. the Reactor Coolant System (RCS) hot and cold leg wide range resistance temperature datectors (RTD), Model Rdr ware not qualifiod in that the junction boxes where the RTD pigtail wires were terminated could becomo submerged and were no'. qualified for submergences the wires were not qualifico for submergence in the lastalled configuration, that is, the hydrostatic hose assembly that was to encapsulate the wires to prevent moisture intrusion had been removed during installations and the qualification file did not addrass the installed configuration as being different from the tested configuration due to submergence.

Response

1. Adminnion or Dental of thn Violatinj Duke Pownr Company admits the violation. This problem was identified by Duku Pownr and reported in I.icensec Event Report 413/88-03.

Catawba Nucicar Station page 2 of 6

. . Duke Power Company Reply to Notice of Violation 413, 414/88-07 I

2. Reasons for_Vg lation if Admitted  ;

J i l The violation occured because of a misinterpretation of notes on drawings

during initial installation. Usually, if vendor supplied es.ble is not [

encored, it is Duke Power's standard practice to add flex conduit over the

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i vendor supplied cable. The RdF RTDs were provided with braid over a sealed  !

bellows hose, not armor. The craft personnel installing the RTDs  ;

i, inadvertently removed the bellows hose assembly when they installed the flex r 1 conduit. This made ..he installation error very difficult to detect. [

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! 3. Corrective Actions Taken and Results Achieved i

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The RTDs have been replaced and a qualified termination seal was installed. f The installation drawings a.d procedures have been revised and training of f i

i craft personnel on correct installation has been completed. This is a very r

unique configuration which is not applicable to other equipment, l 4. Correctivo Actions To Be Taken To Avoid Further Violations l The actions outlined in item 3 above will avoid further violations.

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l S. Date of Full Compliance [

j The unit 1 RTDs were replaced and full compliance was achieved on January 23,  !

j 1988. The unit 2 RTDs were replaced and full compliance was achieved on ,

March 9, 1988.

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10 CFR 50.49(f), (j), and (k) state in part that (1) each item of electrical j equipment important to safety shall be qualified by testing of, or experiones j l

with, identical or similar equipnent, and the qualification shall include a t j supporting analysis to show the equipment to be qualified is acceptables (2) a [

record of qualification must be maintained to verify that each item important to (

safety is qualified for its application and meets its specified performance  !

requirements and (3) electric equipment important to safety which wts previously L

qualified in accordanco with NUREG 0588 (for coceent verrion), "Interim Staf f I I Position on Environmental Qualification of Safety-Related Electrical Equipment "

need not be requalified to 10 CFR 50.49.

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Contrary to the above, from November 30, 1985, until tho timo of an inspection, i which was completed on January 10, 1986, the licensee's environmental  !

qualification (EQ) filos did not adequately document qualification for the two [

! 1.imitorque notor operated valves installed in the Unit 1 Containment Air Return j i and llydrogen Skirner Systen (valve nos. IVX1A and IVX2B). The installed valves l were procured as non-safety without test documentation and the licensee's EQ l files failed to establish similarity between the installed valves and a qualified I

tested configuration. r

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Cattwba Nuclear Station page 3 of 6

. . Duke Powar Company Reply to Notice of Violation 413, 414/88-07 l

Response: '

1. Admissi n or Denial of.the Violatio_n Duke Power Company admits the violation.

2. Reasons for Violation if Admitted This was a documentation violation. The subject valve's Environmental Qualification (54) files were not updated because the original valves were  ;

replaced with fully qualified valves in February. 1986. Supplementing the EQ l file for the orginally supplied valves was considered unnecessary since t.he valves were replaced in February, 1986. Supplemental information sent to the  ;

NRC on March 11, 1988 demonstrated the orginal operators for the valves were l j acceptable.  ;

i 3. Corrective Actions Taken and Results Achieved .

Installation procedures for Limitorque Motor Operated Valves (MOVs) have been fi revised to include an inspection to verify correct application of MOVs for their location. Additionally, training of station personnel which l specifically addresses Limitorque MOV application has been completed. Design  !

Engineering personnel have been instructed in EQ procedures to avoid this type of problem in the future.

4. Correctivo Actions To Be Taken To Avoid Further Violations The actions outlined in item 3 above will avoid further violations.

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5. Date of Full Compliance The valve actuators were replaced and full compilance was achieved in '

i February, 1986.

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{ C. 10 CFR 50.49(f), (j), and (k) state in part that (1) each item of electric L l equipment important to safety shall be qualified by testing of. or '

4 oxperience with, identical or similar equipment, and the qualification shall

] include a supporting analysis to show the equipment to be qualified is 2 acceptables (2) a record of qualification must be maintained to verify that ',

1 each item important to safety is qualified for its application and meets its I specified performanco requirements; and (3) electric equipment important to i

safety which was previously qualified in accordance with NUREG 0588 (for a

coment. version). "Interim Staff Position on Environmental Qualification of j Safety-Related Electrical Equipment" need not be requalified to 10 CFR l

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Catawba Euclear Station page 4 of 6 Duke Power Co.,pany Reply to Notice of Violation 413, 414/88-07

1) Contrary to the above, from initial plant operations until the time of the inspection which was completed on February 5, 1988, a total of three inside containment Limitorque cotor operated valves in Unit I were not installed in accordance with the qualified tested configuration in that T-dr...is were painted over, plugged or not installed. Furthermore, the deficiencies were not evaluated in the i environmental qualification file. The affected valves are identified as follows: 1KC364B, 1KC394A, and 1NM200B.

2) Contrary to the above, from initial plant operation of Unit 2 under the full power license issued on May 15, 1986, until the time of the inspection which was completed on February 5,1988, a total of 17 inside containment Limitorque motor operated valves ware not installed in accordance with a qualified tested configuration in that T-drains were painted over, plugged or not installed. Furthermore, these deficiencieu were not evaluated in the environmental qualification (EQ) file. The affected Unit 2 valves were: 2KC345A, 2KC394A, 2KC413B, 2KC429B, 2NC054A, 2NC250A, 2NC251B, 2NC252B, 2NC253A, 2NM187A, 2NM190A, 2NM197B, 2NM200B, 2NM207A, 2NM210A 2NM025A, and 2WL450A.

Response

1. Admission or Denial of the Violation Duke Power Ccapany admits tho violation.

2. Reasons for Violation if Admitted Installation procedures did not specify requirements for installing T-Drains <

nor did painting procedures address painting over of T-Drains. Supplemental  ;

information sent to the NRC on March 11, 1988 demonstrated the operability of actuators without T-Drains or with painted over T-Drains would not have been l compromtsed.  ;

3. Correctivn Actions Taken and Results Achinved f All Limitorquo MOVs requiring T-Drains havn been inspected and the required T-Drains wore installed or unplugged. Additionally, training of station l painting personnot has boon compinted concerning the painting over of '

T-Drains. Station Instrument arid Electrical (I/J.) procedures have been revised to clarify T-Drain installation requirements. Training for appropriato personnel has been completed on the requirement" for T-Drains.

4. Correctivo Actions To no Taken To Avoid Further Violations The actions outilned in item 3 abovo w!!1 avoid further violations.

5. Date of Full Compilanen r Duko Power is now in full compliance.  ;

Catawba Nuclear Station page 5 of 6 Duke Power Company Reply to Notice of Violation 413, 414/88-07 10 CFR 50.49(f) and (k), state in part that (1) each item of electric equipment important to safety shall be qualified by testing of, or experience with, ident ical or similar equipment, and the qualification shall include a supporting analysis to show the equipment to be qualified is acceptable; and (2) electric equipment important to safety which was previcusly qualified in accorde'ce with NUREG 0588 (for comment version), "Interie Staff Fosition on Environmental Qualification of Safety-Related Electrical Equipment," need not be requalified to 10 CFR 50.49.

Contrary to the above, at the time of the inspection which was completed on February 5, 1988, the Hydrogen Skimmer fan motors on Unit 2 were not installed in accordance with the tested configuration in that the breather drains were not installed and this deficiency was not addressed in the EQ fils.

Response

1. Admission or Denial of the Violation Duke Power Company admits the violation.

2. Reasons for Violation if Admitted The reason for the violation was a vendor maintenance error and lack of I adequate inspection by Duke when the vendot returned the spare f an motors without the breather drains installed. The spare f an motors were returned to l

the fan vendor as part of a modification to the fan motor assemblics.

Subsequently, the assemblics were returned to Duke without the breather drains installed. Supplemental information sent to the NRC on March 11, 1988 demonstrated the operability of the fan motors without the breather drains installed. ..

3. Corrective Actions Taken and Result s Achieved l The solid pluga have been removed from the motors to provide a mechanism for pressure equaliza*.lon under a variation notico. Installation drawings hsve been revised to include specific reference to install breather drains.

4. Corrective Actions To Be Taken To Avoid Further Violations Although Duke provided an analysis which demonstrated the fan motors are qualified without the breather drains, for conservatism, installation of the breather drains has been scheduled upon roccipt of the correct breather drains from the manufacturer.

5. Dete of Full Compliance Duke Power is now in full compliance.

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Catawba Nuclear Station page 6 of 6

'.* . Duke Poar Company i Reply to Notice of Violation ,

413, 414/88-07 l l

10 CFR 50.49(f) and (j) state in part that (1) each item of cicctric equipment  ;

l important to safety shall be qualified by testing of, or experience with,  :

s identical or similar equipment, and the qualification shall include a supporting analysis to show the equipment to be qualified is acceptabin; and (2) a record of [

1 qualification must be maintained to verify that each item important to safety is  ;

qualified for its application and meets its specified performance requirements.

! Contrary to the above, at the time of inspection which was completed on Februar)  !

5, 1988, the file for the Hydrogen Recombiner for Unit 1 did not contain a l

similarity analysis as required to show that the installed tap splice was similar i j to a tested, qualified configuration. [

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Response

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! 1. Admission or Denial of the Violation l

Duke Power Company admits the violation. .

2. Reasons for Violation if Admitted The information to confirm the qualification of the Hydrogen Recombiner tape splice tas available. However, the documentation was in different files and

, thereforo was not in an casily auditable form.

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3. Corrective Actions Taken and Results Achieved i j

The documentation which demonstrates the qualification of the tape splice has

been assembled and placed in the proper file. Also, appropriate personnel a have been trained in EQ documentation procedures.

) 4. Corrective Actions To Bn Taken To Avoid Further Violations 1

i The actions outlined in 3 above will svold future violations, i

5. Date of Full Compliance l

1 Duke Power is now in full coepilance.

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